Vegetarians International Voice for Animals

Viva!’s Submission to the Government’s Consultation on Welfare at Slaughter

When, in April 2004, the Government responded to the 2003 Farm Animal Welfare Report on welfare at slaughter, it invited comments from bodies and organisations with an interest in the issue. In theory, it could change the policy it announced as a result of the consultation process, although in practice this is rare. Viva! submitted the following document to the Government as part of the consultation process.

For more information about the Farm Animal Welfare Council and to download a copy of their report, The Welfare of Farmed Animals at Slaughter or Killing. Part One: Red Meat Animals, see their website,

To see the Government’s “draft response” – which our submission comments on - see


Viva!’s area of concern and expertise in relation to this consultation is that of farmed animal welfare. Our fundamental belief is that the farming of animals for food is morally unacceptable, carries substantial health risks for human beings and represents a catastrophically inefficient and destructive use of land and resources. Viva! opposes all animal slaughter. We recognise, however, that these objections will not be considered relevant to the current consultation and will thus confine our comments to the welfare implications of the Government’s response to the FAWC report.

Viva! welcomes the Government’s acceptance of many of the Council’s recommendations. In this document we shall comment only on the Government responses we consider to be unsatisfactory and conclude by examining the wider context in which these questions arise.


Recommendation 33: electric goads

The use of electric goads is indefensible in all circumstances: a system which requires the direct infliction of pain to function is unacceptable. Furthermore, good design and practice should obviate any “need” for the use of goads. A ban will force abattoirs to improve handling standards overall. Viva! supports the proposed EU ban.

Recommendation 46: approval of equipment

The provision of effective, suitable equipment is essential for animal welfare. If the Government is unable to introduce a mandatory system, it must ensure that there is a centrally-maintained, regularly-updated register or list of approved equipment, including exact specifications for its use. Use of approved equipment should be considered in granting and renewal of licences to slaughterhouses.

Recommendation 52: aversive gases

Evidence suggests that argon or high argon/low CO2 mixtures are effective in inducing unconsciousness with minimal distress and could provide a solution to a number of problems relating to handling and stunning in slaughterhouses. The evidence that CO2 and high CO2 mixtures are aversive, however, is compelling. The use of aversive gases is morally unacceptable and the Government must make active provision to end their use. Commercial questions such as throughput, cost and capital expenditure must not be permitted to override animal welfare. Viva! believes that the use of aversive gases in fact violates the WASK requirement that no “avoidable” pain, excitement or distress should be caused to animals. The Government must commit itself to banning the use of aversive gases.

Recommendation 53: effectiveness of stun

Although the Government have accepted the recommendation that OVSs should monitor tong placement and effectiveness of stun, it does not appear from the draft response that they see a need for any increase in level of monitoring or audit of this critical stage in the slaughter process. It is clear that current standards are wholly unacceptable, leading to a very large number of animals being improperly stunned. One UK study, for instance, found that 36 percent of pigs were stunned using incorrect tong placement (Anil & McIntyre 1993) and FAWC themselves identify “serious deficiencies” in the accuracy of tong placement. Each occasion on which tong placement is incorrect carries a serious risk of ineffective stunning. Due to the huge numbers of animals slaughtered daily in the UK, even a very low level of inadequate stunning would represent an enormous welfare problem. This issue must be addressed with urgency.

OVSs are present at only a fraction of stunnings and it is clear that this level of monitoring is failing significantly to ensure that animal suffering is minimised. Monitoring of every stun should be required by law; stunning effectiveness should be subject to regular audit and legal penalties should be employed if performance falls below 100% effectiveness in any but the most exceptional of circumstances. Records should be kept of every individual operative’s performance and retraining or disciplinary measures mandated as appropriate.

Recommendation 60: wounds of non-stunned animals

Viva! believes that slaughter without prestunning should be banned (see below) but in the absence of a ban, it is essential that all slaughter without prestunning takes place under the direct supervision of an OVS. At present, no records are kept which identify specific welfare problems or violations arising from slaughter without prestunning (source: letter to Viva! from Meat Hygiene Service) but it is absolutely clear that slaughter without prestunning carries the highest possible risk of additional severe suffering in the event of poor practice or technique. Anecdotal evidence shows that a proportion of animals slaughtered without prestunning do remain conscious and active for some time after throat-cutting (Gellatley, 2003). Such occurrences clearly violate the WASK regulation that avoidable pain or distress should not be caused to any animal at slaughter and it is essential that all possible measures to prevent – and to monitor – such occurrences are introduced. If slaughter without prestunning is still to be permitted, OVS supervision of all such slaughter should be mandated by law.

Recommendation 61: slaughter without prestunning

Note: all figures are extrapolated from the MHS Animal Welfare Review 2003. The Review quotes figures for a single week – in the absence of any definitive figures, we have multiplied them by 52 to arrive at an annual estimate. We regret that no more precise figures are available.

Viva! welcomes the Government’s acceptance of FAWC’s conclusion that animals slaughtered without prestunning are likely to experience very significant pain and distress. We therefore find it inexplicable that the Government is unwilling to take any meaningful direct action to address this severe welfare problem. We find the Government’s arguments unconvincing and believe that they misrepresent the nature of this problem and the Government’s options for solving it. We believe that slaughter without prestunning can and should be banned absolutely. We further believe that if the Government remains unwilling to impose a ban, far stronger action can be taken than the Government has indicated it is willing to pursue in the draft response. We shall now examine the Government’s arguments.

Religious Freedom

Firstly, the Government’s characterisation of the situation as “certain religious groups in the UK are constrained from eating meat from animals that are stunned at the time of slaughter” does not acknowledge the diversity and fluidity of the attitudes of Jewish and Muslim people to this issue. As the Government knows, the MHS 2003 Welfare Review found that over 90 per cent of animals killed for halal meat were prestunned during the week it took place. It is clear that the vast majority of people in the Muslim community take a flexible approach to this issue and that there is no contradiction between being a Muslim and eating meat from pre-stunned animals. As the Government also knows, definitions of what constitutes halal vary and in both the UK and abroad – for instance in New Zealand – halal-certifying bodies accept that stunning and halal are consistent with one another. Some Muslims dispute this but they are not a “group” – they are individuals who have a particular interpretation of Islamic law.

Similarly, opinion and practice is divided within the Jewish community. While it is true to say that hostility to prestunning is generally firm within the Orthodox community, many Reform and other Jews do not oppose it and eat meat from stunned animals. Viva! notes that Shechita UK’s website entitles their statement on the Government’s draft response, “Summary of the Jewish Community’s standpoint.” This is simply not true: Shechita UK do not represent all Jews. In the case of both communities, bodies and individuals who represent or claim to speak on behalf of their coreligionists may be vocal in their opposition to slaughter without prestunning but the strength and forcefulness of their opposition must not be mistaken for unanimity or similar strength of feeling within those communities.

Finally, there is no religious requirement to consume halal or kosher meat. Muslims and Jews have the option of not eating meat if they are unwilling to eat it from animals slaughtered without prestunning. As there is a divergence of opinion on this issue within religious communities and as the consumption of meat from animals slaughtered without stunning is not obligatory for Muslims and Jews, a ban would not constitute an infringement of religious practice and would prevent no one from following their religion.

It is also not clear that such a ban would violate the Human Rights Act 1998. On the subject of religious freedom, Article 9 of the Act states:

Freedom to manifest one's religion or beliefs shall be subject only to such limitations as are prescribed by law and are necessary in a democratic society in the interests of public safety, for the protection of public order, health or morals, or for the protection of the rights and freedoms of others.

A ban on slaughter without prestunning may be permissible under the “moral” clause of this Article: if slaughter without prestunning is likely to cause very significant pain and distress then there appears to be a clear moral case for its prohibition. As the Human Rights Act acknowledges, the principle of religious freedom is not superior to other principles and the UK rightly proscribes a number of practices considered to be justified by religious law in other nations and cultures.


The argument that a ban on slaughter without prestunning in the UK would simply lead to the “export” of the problem is not sustainable. Firstly, if this form of slaughter causes severe suffering, Britain has a moral responsibility to legislate against it: in similar circumstances, the Government has banned fur farming in the UK despite the fact that fur may still be imported. Secondly, repealing the current exemption would not necessarily lead to the entire current demand for “non-stunned” halal and kosher meat being met by imports. There is no evidence that this has happened in other countries in which slaughter without prestunning is banned, such as Norway and Sweden. As many Muslims and Jews already eat meat from stunned animals, it is likely that in the event of a ban, others who do not feel strongly about the issue but at present eat meat from unstunned animals would choose meat from stunned animals instead.


The sale of religiously-slaughtered meat in the ordinary meat market effectively subsidises the practice. There is no justification for a system in which consumers who do not agree with slaughter without prestunning are unwittingly providing financial support for it. Even if the Government does not intend to outlaw religious slaughter, it can and should take action to ensure that the cost of this practice is borne solely by those on whose behalf it is undertaken. By increasing the cost of religiously-slaughtered meat, the introduction of compulsory labelling may also contribute towards a decline in its consumption, which will effectively reduce the welfare cost paid by animals.

Secondly, consumers (including Muslim and Jewish people) have a right to information which will allow them to make an informed choice on this issue. Shechita UK maintain that such labelling would be unfair if it was applied only to religiously slaughtered meat. Viva! certainly supports full and detailed labelling about slaughter method on all meat but disputes this argument. Religiously slaughtered meat is exceptional – the law makes an exception for it in permitting slaughter without prestunning. Shechita UK’s argument is also disingenuous. If they believe that traditional Shechita is a high welfare system, why should they object to advertising that fact to consumers?

The Government states that it “would wish” stakeholders to “consider” the options for a voluntary labelling system. It is clear from Shechita UK’s statement that they oppose this idea and have no interest in addressing the practicalities of introducing it. Without extra incentive they, and also some halal producers, simply will not implement such a system. The Government has a responsibility to ensure that the current wholly unacceptable situation does not continue and the passive language employed in the consultation document indicates no such willingness on its part. Nor must the “independent” status of the Food Standards Agency be permitted to allow the Government to disclaim responsibility for the issue. Viva! believes that in the absence of a ban on slaughter without prestunning, a labelling system enforced by meaningful sanctions is absolutely essential. The Government must take whatever steps are necessary to ensure universal uptake of any system.


Slaughter without prestunning is a major welfare issue and one in which hope of voluntary improvement is marginal. While slaughtering for halal is now overwhelmingly conducted with prestunning, over eight million animals a year are still subjected to the unimaginably severe trauma of having their throat cuts while conscious for halal meat and many Muslims continue to support the practice. In the case of kosher meat, although numbers of animals involved are smaller, the situation offers even less hope of progress: resistance to change is absolutely intransigent. Viva! does not doubt the sincerity and integrity of those who believe that prestunning is unacceptable for religious reasons – sadly, it is for precisely this reason that hope for voluntary progress is small. The Jewish and Muslim people who oppose slaughter without stunning hold firmly to a belief that is simply incompatible with animal welfare at slaughter: they will not be swayed by scientific evidence, reasoned argument or even their own genuine concern for animal welfare. Viva! also accepts that many who oppose prestunning have a genuine belief that halal and kosher methods are more humane than conventional slaughter but their fundamental position on this issue is determined by their religious faith and their interpretation of religious law, not considerations of animal welfare. Because many Jewish and Muslim people now consider the consumption of meat from stunned animals totally consistent with their faith, it is also clear that those who do not are the least likely to change their view. Simply put, if the Government does nothing, nothing will be done.

Recommendation 62: post-cut stunning

Post-cut stunning is an essential welfare measure for both cattle and sheep where pre-stunning does not occur. At present, MHS figures suggest that over 900,000 sheep and lambs are slaughtered without any form of stunning and 20,000 cattle. The evidence that cattle retain consciousness for periods measured in tens of seconds and even minutes is the most compelling and unambiguous of all the evidence of animal suffering arising from slaughter without prestunning. While sheep take less time to lose consciousness, even 5 or 10 seconds of severe wound pain and shock secondary to exsanguination remains a profound welfare insult. It is absolutely clear that severe suffering of this kind is both intolerable and “avoidable”: in the light of current knowledge and existing law, it is unacceptable that it should still be permitted.

In the case of cattle, almost all slaughtered for halal meat are now prestunned with the tiny remainder given a post-stick stun. Post-cut stunning already takes place in half of Shechita cattle slaughterings and so it is clear that opposition to it reflects not universal opinion within the Jewish community but a sectional view. The Government must not allow the conservatism and intransigence of any group or body to override the compelling need to address the profound suffering of cattle undergoing this form of slaughter. MHS figures suggest that introducing post-cut stunning for all cattle would affect just 20,000 animals per year – barely 0.2% of the total number of animals slaughtered without prestunning – but although numbers of animals are relatively small, such a measure would address the single most severe welfare problem to arise from religious slaughter. Again, however, voluntary action is doomed to failure. Shechita UK, for instance, have painted themselves into a corner on this issue: for them to accept post-cut stunning would be to concede that there is a welfare problem arising from Shechita and it is now absolutely clear that they will not do this. This situation can only be solved by action at governmental level.

To fail to introduce a measure that would have so insignificant an impact on the prevalence and practice of religious slaughter but would so substantially reduce the severe suffering of tens of thousands of individual animals would be a total dereliction of the Government’s responsibility to protect animal welfare. It would also act as a sign that the Government will capitulate to any level of opposition arising from religious quarters, however detrimental in its consequences and however small in scale the issue at stake. If the Government remains unwilling to impose a ban, Viva! implores it to take the absolutely minimal step of mandating post-cut stunning by whatever means will prove effective.

Recommendations 63 and 64: bleeding within sight of conspecifics and stun-to-stick times

Stun-to-stick times are critical in ensuring that stunned animals do not regain consciousness before knifing. The margin for error when electrical stunning is likely to induce unconsciousness lasting for considerably less than one minute in sheep and pigs (Cook et al 1995) is very small. Viva!’s examination of this problem indicates that millions of red meat animals each year regain consciousness before slaughter (Smith, 2000). The most recent MHS figures indicate that stun-to-stick times of over 15 seconds occur in many abattoirs – for instance, in 24 abattoirs slaughtering fat pigs during the 2003 welfare review – and it is clear that a substantial number of animals will regain consciousness before death. The prevalence of this problem indicates an urgent need for a measure which will ensure stun-to-stick times of the shortest possible duration. Although WASK mandates loss of consciousness lasting until death, OVSs are not able to monitor every slaughtering and animals may in any case regain consciousness after sticking without this being detectable to an observer. A maximum stun-to-bleed time of 15 seconds laid down in legislation would provide a measurable and thus enforceable mechanism to minimise the possibility of recovery. Such a measure must be introduced.

Recommendation 65: severing of carotid arteries

If severing of both carotid arteries is not legally permissible for meat hygiene reasons then stun-to-stick times must be revised downwards to take account of the longer bleeding time.

Recommendations 70, 71 and 72: slaughter of deer

In responding to these recommendations the Government appears to be working on the principle that deer’s specific needs are secondary to the commercial considerations of slaughterhouse provision. The principle should instead be that where facilities suitable for slaughtering deer do not exist within the local area, deer should not be reared. It should be the responsibility of the producer to ensure that suitable facilities for slaughter are available and the Government should embody this principle in any legislative changes it introduces.

Recommendation 72: ratites

Ratites are barely-domesticated, dangerous animals, wholly dissimilar physiologically to any other animals killed for food in the UK. Evidence about their welfare needs is insufficient to ensure that they can be safely and efficiently slaughtered in a manner which protects their welfare. In the absence of sufficient skill and knowledge, ostriches should not be slaughtered – and thus not be reared - in the UK.

Recommendations 80, 81 and 82: training and licencing

Poor practice in such areas as handling and stunning can and does have a profound impact on animal welfare (see Recommendation 53). A formal system of training, assessment and licencing is essential for raising and maintaining standards. OVSs’ monitoring of practice is not systematic or centred on individuals and therefore not an adequate substitute for formal systems.

Recommendations 87, 88 and 89: animal welfare officers

Welfare has no central role within slaughterhouses – which exist to process meat as efficiently and profitably as possible – and attention devoted to it comes at a financial cost. The OVS’s primary responsibility is to enforce existing law rather than promote welfare. It is therefore essential that at least one designated individual who is employed by the establishment is given formal responsibility, by law, for promoting and ensuring animal welfare and is formally trained in the subject.

Recommendation 93: OVS auxiliaries

While auxiliaries are no substitute for fully trained and professionally-accountable veterinary surgeons, they could clearly contribute to a raising of standards. Funding for the training of auxiliaries should be provided by Government or from a levy on abattoirs.


The Government’s acceptance of the majority of the Farm Animal Welfare Council’s recommendations is very welcome. In many cases the Government’s acceptance does not, however, amount to a firm commitment to take substantive measures and we hope that the processes of “consultation”, “exploration” and so on will not prove to be a substitute for meaningful action. Nevertheless, it is clear that animal welfare at slaughter should improve as a result of the Government’s response to the report.

Unfortunately, there are a number of major issues on which the Government’s response is unsatisfactory: chief among these are slaughter without prestunning, the use of aversive gases and inadequate stunning. In common with lesser but still significant issues such as training and the handling of deer, it seems clear that the principle guiding the Government’s response has been narrow pragmatism rather than animal welfare. Acceptance or rejection of FAWC’s individual recommendations appears to depend on the ease of taking action, rather than any value each may have in reducing animal suffering.

Aversive gases cause animal suffering. CO2 is used in preference to argon because it is cheap and allows a faster throughput of animals. Accordingly, the industry likes it and has no desire to invest in more welfare-friendly but expensive techniques. The Government is unwilling to take any action that would accelerate change towards gas stunning/killing methods which will cause less animal suffering, despite the large numbers of animals involved and the substantial welfare benefit achievable.

Similarly, accurate, skilled stunning and minimal stun-to-stick times are the central mechanism for ensuring that animals do not suffer in the most severe way at slaughter. Thorough, comprehensive and verifiable monitoring of these parts of the slaughter process would, however, be a relatively complex and potentially costly step for producers and the MHS. The Government’s response to this problem has again, therefore, been to take no effective action, despite the substantial welfare benefit that would accrue.

Lastly, slaughter without prestunning affects an estimated ten million animals including around one million red meat animals per year. The Government accepts that it is likely to cause very significant pain and distress. Again, however, pragmatism rules: the level of opposition to any form of mandatory change will be strong (even if it actually stems from a very small number of people or from groups who may not even be representative of the communities on whose behalf they claim to speak and even though 71% of the UK public want a ban on slaughter without prestunning) so the Government will take no action. Attempts to foster voluntary change will fail because those who support slaughter without prestunning have made it very apparent that they have no interest in or desire to change. The measures announced by the Government amount to an abdication of responsibility.

In these respects, as in so many others, it is apparent that animal welfare assumes a far lower priority in policy-making than commercial or indeed political considerations. Welfare measures are welcome so long as they incur no significant cost. As soon as they come into conflict with other interests, the political will to implement them evaporates. Viva!’s opinion on this issue is not determined by prejudice, cynicism or hostility to the Government – simply by observing the Government’s behaviour on a range of issues from hunting through to innumerable aspects of farmed animal welfare. We regret that the Government’s draft response to FAWC’s report has failed to tackle the most pressing and difficult issues it raised. We implore the Government to reconsider their position in all the areas we have highlighted but especially the use of aversive gases, the effectiveness of stunning and slaughter without prestunning. We remain hopeful that the Government will take this opportunity to deliver truly significant improvements in animal welfare at slaughter.


  1. Cook CJ et al (1995) The effect of electrical head-only stun duration on electroencephalographic-measured seizure and brain amino acid neurotransmitter release Meat Science 40 137-47
  2. Anil MH & McIntyre JL (1993) Variations in electrical stunning tong placements and relative consequences in slaughter pigs The Veterinary Journal 55 85-90
  3. Gellatley J (2003) Going for the kill: Viva! report on religious slaughter Viva! 2003
  4. Meat Hygiene Service (2004) Animal Welfare Review 2003 Meat Hygiene Service
  5. Shechita UK website (2004)
  6. Smith R (2000) Sentenced to Death: a Viva! Report on the slaughter of farmed animals in the UK Viva!
  7. Wotton S (1996) Sticking techniques and exsanguinations in pigs, sheep and calves Meat Focus International (July) 234-7